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United States securities and exchange commission logo
October 4, 2023
James Kehoe
Chief Financial Officer
Fidelity National Information Services, Inc.
347 Riverside Avenue
Jacksonville, FL 32202
Re: Fidelity National
Information Services, Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2022
Response dated
September 20, 2023
File No. 001-16427
Dear James Kehoe:
We have reviewed your September 20, 2023 response to our comment
letter and have the
following comments. In some of our comments, we may ask you to provide
us with information
so we may better understand your disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your response to these comments, we may have
additional
comments. Unless we note otherwise, our references to prior comments are
to comments in our
September 6, 2023 letter.
Form 10-K for the Fiscal Year Ended December 31, 2022
Management's Discussion and Analysis of Financial Condition and Results
of Operations, page
31
1. We note your response
to prior comment 2 that you do not directly emit GHG emissions
as a byproduct of your
business. However, your Global Sustainability Report discloses
Scope 1, 2 and 3
emissions. We further note such report states that your real estate
portfolio is critical
to pursuing ESG excellence as it relates to energy efficiency and
renewable energy, and
that you may be exposed to new costs from potential government-
imposed carbon tax or
cap and trade schemes. Please explain in greater detail your
analysis of the
following indirect consequences of climate-related regulations or business
trends and any
conclusions as to materiality:
James Kehoe
Fidelity National Information Services, Inc.
October 4, 2023
Page 2
decreased demand for goods or services that produce significant
greenhouse gas
emissions or are related to carbon-based energy sources;
increased demand for goods that result in lower emissions than
competing products;
increased competition to develop innovative new products that
result in lower
emissions; and
increased demand for generation and transmission of energy from
alternative energy
sources.
In addition, please discuss potential reputational risks resulting
from operations or
products that produce material greenhouse gas emissions.
2. We note your response to prior comment 3. Please further address the
following:
We note your risk factor on page 15 discussing that your systems
and operations
could be exposed to damage or interruption from severe weather
events and other
natural disasters. Please tell us how you considered disclosing the
uncertainties and
risks of climate-related physical effects on your business and
operations around the
world. In that regard, we note your Global Sustainability Report
reflects that the
TCFD assessment found that water stress may pose a risk to you, and
you are
planning to take measures to mitigate risks associated with water
stress.
Please discuss how your business and operations could be impacted
to the extent your
customers or suppliers are impacted by severe weather.
Your response quantifies your increase in insurance premiums.
Please also quantify
the cost of insurance premiums for each of the periods covered by
your Form 10-K.
Please contact Michael Purcell at 202-551-5351 or Karina Dorin at
202-551-3763 with
any questions.
FirstName LastNameJames Kehoe Sincerely,
Comapany NameFidelity National Information Services, Inc.
Division of Corporation
Finance
October 4, 2023 Page 2 Office of Energy &
Transportation
FirstName LastName